Privacy Policy – Information on Data Protection and Your Privacy (As of June 2024)

1. Controller and Data Protection Officer

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The entity responsible for data protection in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, repealing Directive 95/46/EC (GDPR) is:

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Controller according to Art. 4 Para. 7 GDPR is

justmatch UG (haftungsbeschränkt)
Abelke-Bleken-Ring 18A
21037 Hamburg

Telefon: +49 175 1969035
E-Mail: dataprotection@justmatch.wtf

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Our Data Protection Officer can be reached at

justmatch UG (haftungsbeschränkt)
Abelke-Bleken-Ring 18A
21037 Hamburg

E-Mail: dataprotection@justmatch.wtf

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2. Commitment to Data Protection and Privacy

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justmatch places great importance on protecting and maintaining the confidentiality of your personal data. Our goal is to actively support you in your search for your dream job and to be your personal career companion. Trust is the foundation of the relationship between Justmatch and you. You can be assured that Justmatch is fully committed to protecting your privacy and your right to data protection. Protecting your data from unauthorized access is a top priority for justmatch. We collect and use personal data exclusively in accordance with European and national data protection regulations. Below, we provide information about the nature, scope, and purpose of the collection and use of personal data. You can access this information at any time at https://justmatch.wtf/datenschutzerklärung.

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3. Subject of this Privacy Policy

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This privacy policy applies to all services offered under the domain "justmatch.wtf" and the app named "justmatch" (hereinafter referred to as the "App"). The subject of data protection is personal data. According to Art. 4 No. 1 GDPR, personal data includes all information related to an identified or identifiable person. This includes details such as name, email address, location data, and online identifiers. We provide more details about this in connection with the specific processing activities on our website and in the app.

Further definitions of terms can be found in Art. 4 GDPR.

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4. Data Collection When Visiting Our Website

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4.1 Server Log Files

When you visit our website, we only collect the personal data that your browser transmits to our server. This information is temporarily stored in so-called log files. The following information is automatically collected and stored until automated deletion:

• IP address
• Browser type, language, and version
• Operating system
• Access status/http status code
• Date and time of the request, including time zone
• Content of the request and the website from which it originated

The mentioned data is collected to display our website to you and to ensure stability and security.

The legal basis for this data collection is Art. 6 Para. 1 lit. f GDPR. Our legitimate interest arises from the aforementioned purpose of data collection.

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4.2 Company Account

justmatch offers recruiters the opportunity to create a company profile. When creating a company profile, Justmatch collects the following user data:

• First and last name
• Email address
• Company name
• Date of profile creation
• Possibly a photo of the recruiter

The legal basis for processing this data is the fulfillment of the contract between you as a user and us in accordance with Art. 6 Para. 1 lit. b GDPR for the use of the company profile, and possibly your consent in accordance with Art. 6 Para. 1 lit. a GDPR.

The data will be stored for the duration of the contract.

The user must provide the above-mentioned data, and the information must be truthful. Justmatch is entitled to request proof from the user at any time at its own discretion. If the user does not provide the requested proof within 2 weeks of receiving the corresponding request, Justmatch may block the user profile.

nicht innerhalb von 2 Wochen nach Erhalt der entsprechenden Aufforderung, kann Justmatch das Nutzerprofil sperren.

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4.3 Web analytics

For web analytics, we use Pirsch Analytics. Pirsch Analytics is a cookie-free web analytics software that was developed according to the Privacy by Design principle. To analyze visitor flows, Pirsch Analytics uses a hashing algorithm to generate a 16-digit number as the visitor ID when the page request is received. The input values are the IP address, the user agent, the date and a salt.

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The visitor's IP address is not persisted in whole or in part, and is anonymized completely and non-reversibly by the hash. The inclusion of the date and the use of one salt per website ensures that website visitors cannot be recognized for more than 24 hours and cannot be tracked across multiple websites. A rough localization (country/city) is performed via a locally integrated database.

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5. Data Processing When Using the "justmatch" Mobile Application for Android and iOS

justmatch offers a platform through its mobile application to match user profiles with specific job profiles. This service is free for users. Users create a profile with the data specified in section 5.3. Justmatch matches this data with available job profiles. If the analysis shows that the user profile and job profiles have a complete match (Matching), the mobile application presents specific job offers to the user. The user can save these matches in a favorites list (Yay Zone) and apply directly through the respective company's applicant management system if desired.

Information on the Processing of Your Data

Certain information is automatically processed as soon as you use the app. Below, we list the specific personal data that is processed:

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5.1 Information Collected During Download

When downloading the app, certain necessary information is transmitted to the App Store you have selected (e.g., Google Play or Apple App Store). This may include the username, email address, customer number of your account, time of download, payment information, and the unique device identifier. The processing of this data is carried out solely by the respective App Store and is beyond our control.

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5.2 Information Automatically Collected

During your use of the app, we automatically collect certain data necessary for the use of the app. This includes: [internal device ID, version of your operating system, time of access, IP address, content of the access].

This data is automatically transmitted to us but not stored. It is used to (1) provide you with the service and related functions, (2) improve the functions and performance features of the app, and (3) prevent and address misuse and malfunctions. This data processing is justified because (1) the processing is necessary for the fulfillment of the contract between you as the user and us according to Art. 6 Para. 1 lit. b GDPR for the use of the app, or (2) we have a legitimate interest in ensuring the functionality and error-free operation of the app and in offering a market-oriented service, outweighing your rights and interests in the protection of your personal data according to Art. 6 Para. 1 lit. f GDPR.

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5.3 Data Collection During Profile Creation (mobile application)

justmatch offers its users the opportunity to create a comprehensive profile. When creating a user profile, Justmatch collects the following user data:

• Username
• Email address
• List of user skills
• User preferences regarding job conditions
• Date of profile creation

The legal basis for processing this data is the fulfillment of the contract between you as a user and us according to Art. 6 Para. 1 lit. b GDPR for the use of the app and, if applicable, your consent according to Art. 6 Para. 1 lit. a GDPR.

Additionally, you can delete your profile at any time under account settings.

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5.4 Use of the App

When using the app, you can enter, manage, and edit various information, tasks, and activities.

The app also requires the following permissions:

• Internet access: Needed to store your inputs on our servers.
• Push notifications: Used to send you targeted push messages, such as job reminders.
• Email notifications: Needed to send you targeted emails with additional information, such as job reminders.

The permissions to access the above functions are explicitly requested at the latest upon first use on the device and can be accepted or declined.

A granted permission can usually be revoked at any time in the device settings (this depends on the device and operating system, which we have no control over).

Permissions that are not granted will restrict the use of the app. However, all functions not affected by the permission will remain usable.

The processing and use of usage data are carried out to provide the service. This data processing is justified as the processing is necessary for the fulfillment of the contract between you as the user and us according to Art. 6 Para. 1 lit. b GDPR for the use of the app. If you have given us your consent for the individual permissions, the processing is based on this consent according to Art. 6 Para. 1 lit. a GDPR.

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5.5 Managing Email Addresses and Sending Messages

When the user allows Justmatch to communicate via email, Justmatch collects data about the date and time an email is read by the user, as well as when the user interacts with incoming email messages, for example, by clicking on links contained in the email. Justmatch utilizes the technology of Twilio SendGrid for this purpose.

Twilio SendGrid is a service provided by Twilio Inc. for managing email addresses and sending messages. This transfer is carried out in accordance with Art. 6 Para. 1 lit. f GDPR and serves our legitimate interest in using an effective, secure, and user-friendly newsletter system. For more information about the service provider Twilio SendGrid, see here:

• Service Provider: Twilio Inc.
• Address: 375 Beale Street, Suite 300, San Francisco, CA 94105, USA
• Privacy Policy: https://www.twilio.com/legal/privacy

Since the transfer of personal data occurs to the USA, additional protection mechanisms are required to ensure the data protection level of the GDPR. To guarantee this, we have agreed on standard data protection clauses with the provider in accordance with Art. 46 Para. 2 lit. c GDPR. These clauses obligate the recipient of the data in the USA to process the data according to the protection level in Europe. In cases where this contractual extension cannot ensure adequate protection, we strive for additional agreements and commitments from the recipient in the USA.

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6. Transfer of Your Data

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The transfer of personal data to third parties for purposes other than those mentioned in this privacy policy does not take place. We only share your data with third parties if:

• You have given your explicit consent according to Art. 6 Para. 1 lit. a GDPR.
• The disclosure is necessary for the establishment, exercise, or defense of legal claims pursuant to Art. 6 Para. 1 lit. f GDPR, and there is no reason to believe that you have an overriding legitimate interest in not disclosing your data.
• There is a legal obligation for the transfer according to Art. 6 Para. 1 lit. c GDPR.
• This is required for the fulfillment of contractual relationships with you according to Art. 6 Para. 1 lit. b GDPR.

In addition, we use external service providers to provide our services. These providers are carefully selected by us and act only on our behalf (data processing agreement according to Art. 28 GDPR). These are generally service providers in the fields of IT, service maintenance, cloud providers, and web hosting.

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7. Data Retention Period

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We delete or anonymize your personal data as soon as it is no longer necessary for the purposes for which we collected or used it according to the preceding sections. As a rule, we store your personal data for the duration of the usage or contractual relationship established with us and, within the scope of the usage or contractual relationship through the app, plus a period of 14 days during which we keep backup copies after deletion, unless these data are needed longer for criminal prosecution or to secure, assert, or enforce legal claims.

Specific provisions in this privacy policy or legal requirements for the retention and deletion of personal data, especially those we must retain for tax reasons, remain unaffected.

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8. Rights of Data Subjects

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Users can assert the following rights regarding their personal data at any time via email at info@justmatch.wtf or in writing to the address provided in section 1:

• Right of access (Art. 15 GDPR)
• Right to rectification (Art. 16 GDPR)
• Right to erasure (Art. 17 GDPR)
• Right to restriction of processing (Art. 18 GDPR)
• Right to data portability (Art. 20 GDPR)

Users also have the right to withdraw consent at any time (Art. 7 Para. 3 GDPR). In this case, Justmatch will delete all personal data unless legally obligated to retain it. Such withdrawal may result in the user no longer being able to use the app or only having limited use.

Users can also file a complaint with the relevant supervisory authority (Art. 77 GDPR). The relevant supervisory authority is the Hamburg Commissioner for Data Protection and Freedom of Information, Ludwig-Erhard-Str 22, 7th Floor, 20459 Hamburg, mailbox@datenschutz.hamburg.de.

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9. Right to Object

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Insofar as we base the processing of your personal data on the pursuit of legitimate interests (Art. 6 Para. 1 lit. f GDPR), you can object to the processing on grounds relating to your particular situation. If your objection is directed against the processing of personal data for direct marketing purposes, you have a general right to object without the need to provide a particular situation.

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10. Changes to This Privacy Policy

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justmatch reserves the right to change this privacy policy. In particular, Justmatch reserves the right to change these data protection provisions if the legal framework conditions change or if national or European case law requires it. The current version applies at all times.

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This privacy policy is effective as of June 2024.